AVIV PRIVACY NOTICE

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Last Updated: February 18, 2025

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Aviv, operated by 1 Hotel South Beach, and its affiliate and subsidiaries (“Aviv,” “we,” “us,” or “our”)
respects your privacy. This Privacy Notice (“Notice”) describes the processing of Personal Information
(defined below) that is provided, collected, or disclosed while providing our products or services to you
(“Services”) and on the websites, applications and online platforms that link to this Notice (collectively,
“Site”).
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Please   read   this   Notice   carefully   to   understand   our   policies   and   practices   regarding   your   Personal
Information and how we will treat it. To access this Notice in an alternative downloadable format, please
click here.
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Personal Information We Collect
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We may collect several categories of Personal Information from and about users of our Site and Services.
“Personal Information” means information that uniquely identifies, relates to, describes, or is reasonably
capable of being associated with or linked to you. The categories of Personal Information we collect may
include:

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Contact Information – If you submit an inquiry, register for an account, or provide information on
or through our Site or Services, we may collect your contact information including your name,
mailing address, email address, and phone number.

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Commercial Information – If you submit an inquiry, or provide information on our Site, we may
collect commercial information including information about your purchases, subscriptions, and
Services you have shown interest in.

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Usage Information – When you use our Site, we may automatically record information, including
your Internet Protocol address (IP Address), geolocation of your device, browser type, referring
URLs (e.g., the website you visited before coming to our Site), domain names associated with your
internet service provider, and any other information regarding your interaction with our Site.

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Communication Information  –  We   may   collect   Personal   Information   contained   within   your
communications with us via email, social media, telephone, or otherwise, and in certain cases we
may use third-party service providers to do so. Where permitted by applicable law, we may collect
and maintain records of calls and chats with our agents, representatives, or employees via message,
chat, post, or similar functionality.

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How We Collect Personal Information

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Directly From You – We collect Personal Information that you provide to us directly, for
example, if you choose to contact us, request information from us, sign up to receive updates, or
otherwise utilize our Site or Services.
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From Third Parties – We may collect Personal Information from third parties, including but not
limited to business partners, advertising networks, social networks, data analytics providers,
mobile device providers, Internet or mobile service providers, recruiters and job application
portals, and background check providers.
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Through Online Tracking Technologies – We use cookies and similar technologies to collect
Personal Information automatically as you navigate our Site. For additional information regarding
our use of these technologies, see the Cookies and Tracking Technologies section below.
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How We Use Personal Information

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To the extent permitted by applicable law, we use Personal Information:

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To provide and personalize our Site and Services, such as processing or fulfilling orders and
reservations, providing and personalizing our Services, processing payments, providing customer
service,   maintaining   or   servicing   accounts,   verifying   customer   information,   creating   and
maintaining business records, verifying eligibility, and undertaking or providing similar services.

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To optimize, improve, and maintain our Services, including understanding how users interact with
our Services, gauging user interest in certain Services or Site functionality, and troubleshooting
problems.
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For internal research and development, such as testing, verifying, and improving the quality of our
Services or developing new ones.

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For marketing and advertising, including using your information to send you messages, notices,
newsletters, surveys, promotions, or event invitations about our own or third parties’ goods and
services that may be of interest to you. You can unsubscribe from any marketing emails or text
messages that we may send you by following the instructions included in the email or text
correspondence or emailing us at privacy@shhotelsandresorts.com.

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For communicating with you, such as responding to your questions and comments or notifying you
of changes to our Site or Services.

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For legal, security, or safety reasons, such as protecting our and our users’ safety, property, or
rights; complying with legal requirements; enforcing our terms, conditions, and policies; detecting,
preventing, and responding to security incidents; and protecting against malicious, deceptive,
fraudulent, or illegal activity.

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As part of a corporate transaction, such as in connection with the sale of part or all of our assets or
business, the acquisition of part or all of another business or another business’ assets, or another
corporate transaction, including bankruptcy.

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To fulfill any other purpose for which you provide it, including purposes described when you
provide the information or give your consent.

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How We Disclose Personal Information

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We may disclose aggregated information about our users, and information that does not identify any
individual, without restriction.

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We may disclose your Personal Information with your consent or in the following circumstances:

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Employees and Other Personnel – We may share Personal Information with our employees and
personnel who have a need to know the information for our business purposes.
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Affiliates and Subsidiaries – We may share Personal Information within our family of companies
for their and our business and marketing purposes, including providing you with information
about the Services we think may be of interest to you.

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Service Providers – We disclose your Personal Information with the service providers that we use
to support our business, including but not limited to, data analytics providers, website hosting
providers, and other technology providers. If you are applying for a job with us, this may include
service providers such as background check providers and human resource providers.
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Business Partners – We may disclose Personal Information with trusted business partners. For
example, we may disclose your Personal Information with a company whose products or services
we think may be of interest to you or who we co-sponsor a promotion or service with.
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Legal Obligation or Safety Reasons – We may disclose Personal Information to a third party
when we have a good faith belief that such disclosure of Personal Information is reasonably
necessary to (a) satisfy or comply with any requirement of law, regulation, legal process, or
enforceable governmental request, (b) enforce or investigate a potential violation of any
agreement you have with us, (c) detect, prevent, or otherwise respond to fraud, security or
technical concerns, (d) support auditing and compliance functions, or (e) protect the rights,
property, or safety of Aviv, its employees and clients, or the public against harm.
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Merger or Change of Control – We may disclose Personal Information to third parties as
necessary if we are involved in a merger, acquisition, or any other transaction involving a change
of control in our business, including but not limited to, a bankruptcy or similar proceeding. Where
legally required, we will give you notice prior to such disclosure.
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Other – We may disclose Personal Information to third parties when explicitly requested by or
consented to by you, or for the purposes for which you disclosed the Personal Information to us
as indicated at the time and point of the disclosure (or as was obvious at the time and point of
disclosure).

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Cookies and Other Tracking Technologies

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We and our service providers may use cookies and similar technologies to collect usage and browser
information about how you use our Site. The technologies we use for this automatic data collection may
include cookies and web beacons that permit us to verify system and server integrity and generate statistics
around the popularity of certain content. We process the information collected through such technologies,
which may include or be combined with Personal Information, to help operate certain features of our Site, to
enhance your experience through personalization, and to help us better understand the features of our Site
that you and other users are most interested in.

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Website Analytics– We use analytics services, that use cookies and other technologies that collect your
Personal Information, to assist us with analyzing our Site traffic and site usage to optimize, maintain, and
secure our Site and inform subsequent business decisions (including, e.g., advertising). These include, but
are not limited to, the following third-party services:
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- Google Analytics: To learn more about how Google uses data, visit Google’s Privacy Policy and
Google’s page on “How Google uses data from sites or apps that use our services.” You may
download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this
does not prevent the use of other analytics tools. To learn more about Google Analytics cookies,
visit Google Analytics Cookie Usage on Websites.
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Cookie Choices – To manage your preferences with respect to these technologies, you can:

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- Visit our preferences page, or customize your browser settings to refuse all or some browser
cookies, or to alert you when websites set or access cookies. If you disable certain cookies, please
note that some parts of our Site may not function properly. These settings may be lost and require
reconfiguration if you delete your cookies.

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- Block the collection and use of your information by online platforms and ad tech companies for the
purpose of serving interest-based advertising by visiting the opt out pages of the self-regulatory
programs of which those companies are members:  National Advertising Initiative  and  Digital
Advertising Alliance      (or the European Interactive Digital Advertising Alliance, if you are located in
the European Economic Area). Please note that even if you opt out of interest-based advertising,
you may still see “contextual” ads which are based on the context of what you are looking at on the
websites and pages you visit.
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- Review and execute any provider-specific instructions to customize your preferences or opt-out of
certain   processing,   including   interest-based   advertising,   by   third-party   service   providers.   For
example, to opt-out of this type of advertising by Google, customize your ad preferences, or limit
Google’s collection or use of your data, visit Google’s Safety Center and Google’s Ad Settings and
follow Google’s personalized ad opt-out instructions.
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How Long We Keep Your Personal Information

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We retain your information for as long as needed: (i) to conduct business with you; (ii) fulfill the purposes
outlined in this policy; and (iii) to comply with our legal obligations, resolve disputes, and enforce any
agreements.
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Criteria we will use to determine how long to retain your Personal Information include the nature and length
of our business relationship with you; our legal rights, obligations, and retention requirements; and if we
have an ongoing business purpose for retaining your Personal Information, such as communicating with you
about ongoing or prospective Services you requested.

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Links to Third-Party Websites

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We are not responsible for the practices employed by any websites or services linked to or from our Site,
including the information or content contained within them. We encourage you to investigate and ask
questions before disclosing Personal Information to third parties, since any Personal Information disclosed
will be handled in accordance with the applicable third party’s privacy policy.

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International Use and Cross-Border Data Transfers

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If you are visiting our Site from outside of the United States, please note that our Site is hosted in the United
States. Where permitted by applicable law, we may transfer the personal data we collect about you to the
United States and other jurisdictions that may not be deemed to provide the same level of data protection as
your home country, as necessary for the purposes set out in this Notice.

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How We Protect Personal Information

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We have implemented commercially reasonable measures designed to secure your Personal Information
from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the
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transmission of information via the internet is not completely secure. Despite these efforts to store Personal
Information in a secure environment, we cannot guarantee the security of Personal Information during its
transmission or its storage on our systems.

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Children’s Privacy

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We do not knowingly collect or solicit any Personal Information from children, as defined under applicable
law, without verified written parental consent, and we have no actual knowledge of selling such Personal
Information of minors under 16 years of age. If we learn that we have collected Personal Information from a
child, we will promptly take steps to delete that information. If you believe we might have any information
from or about a child, please contact us at privacy@shhotelsandresorts.com.

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Changes to this Notice

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Please note that we may modify or update this Notice from time to time, so please review it periodically.
If we make material changes to how we treat Personal Information, we will notify you according to
applicable law. Unless otherwise indicated, any changes to this Notice will apply immediately upon
posting to our Site. You are responsible for periodically visiting our Site and this Notice to check for any
changes.

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Contact Us

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If you have any questions about our practices or this Notice, please contact us at
privacy@shhotelsandresorts.com.

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